No justification or viability information has been provided to support the increase from 28% to 33% affordable housing within the draft plan. The 28% figure was confirmed through the 2017 SHMA and we are not aware that there has been any update to the SHMA, or any other evidence that would support this change. Unless there is compelling new evidence to support the increase to 33%, then the requirement should remain at 28% in line with the latest SHMA.

The term “at least” should be removed from the policy prior to each percentage requirement as this does not provide the necessary certainty for developers. Affordable housing policies should not be seeking to establish requirements as minimums.

Lanpro object to Student accommodation schemes being asked to provide a commuted sum equivalent to the amount of affordable housing that would be expected if the site was developed for general needs housing. This will be very difficult to accurately assess without an alternative housing scheme being drawn up to take into account individual site constraints and viability and market factors. What will be the mechanism for agreeing this? It is too simplistic to consider doing it on a site area basis and is likely to delay schemes coming forward and potentially affect viability.

Student housing is meeting a particular identified housing need in its own right as evidenced by Norwich City Council’s Student Accommodation Need Assessment.

The policy requires C3 accommodation for older people to provide on-site affordable housing and this provides insufficient flexibility. Such affordable housing provision has proven to be incompatible with managed sheltered housing developments as housing providers are often unwilling to take on such units. We are concerned that the policy would stifle delivery of sheltered housing accommodation. Such an approach conflicts with the positive approach towards housing delivery contained within the NPPF and as such is unsound. Accommodation for older people should not be required to provide onsite provision for affordable housing and should instead be required to provide a commuted sum in lieu of provision. The policy should be amended accordingly.